throbber
Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 1 of 29
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`AML IP, LLC,
`
`
`Plaintiff,
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`
`
`v.
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`
`
`
`TENCENT AMERICA LLC
`Defendant.
`
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`)
`)
`)
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`)
`)
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`Civil Action No. 1:21-cv-04090
`
`JURY TRIAL DEMANDED
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`MANHATTAN DIVISION
`
`
`
`
`PLAINTIFF’S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT
`
`
`
`
`AML IP, LLC (“AML”) files this Original Complaint and demand for jury trial seeking
`
`relief from patent infringement of the claims of 7,177,838 (“the ‘838 patent”) (referred to as the
`
`“Patent-in-Suit”) by Tencent America LLC (“Tencent”).
`
`
`
`I.
`
`THE PARTIES
`
`1. Plaintiff AML is a Texas Limited Liability Company with its principal place of business
`
`located in Travis County, Texas.
`
`2. On information and belief, Tencent is a limited liability company existing under the laws
`
`of the State of California, with a principal place of business located at 7 Bryant Park. New York,
`
`US 10018. On information and belief, Tencent sells and offers to sell products and services
`
`throughout New York, including in this judicial district, and introduces products and services that
`
`perform infringing methods or processes into the stream of commerce knowing that they would be
`
`sold in New York and this judicial district. Tencent may be served through Paracorp Incorporated,
`
`2804 Gateway Oaks Dr. #100, Sacramento, California, 95833 or anywhere thay may be found.
`
`II.
`
`JURISDICTION AND VENUE
`
`1
`
`
`
`
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 2 of 29
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`3. This Court has original subject-matter jurisdiction over the entire action pursuant to 28
`
`U.S.C. §§ 1331 and 1338(a) because Plaintiff’s claim arises under an Act of Congress relating to
`
`patents, namely, 35 U.S.C. § 271.
`
`4. This Court has personal jurisdiction over Defendant because: (i) Defendant is present
`
`within or has minimum contacts within the State of New York and this judicial district; (ii)
`
`Defendant has purposefully availed itself of the privileges of conducting business in the State of
`
`New York and in this judicial district; and (iii) Plaintiff’s cause of action arises directly from
`
`Defendant’s business contacts and other activities in the State of New York and in this judicial
`
`district.
`
`5. Venue is proper in this district under 28 U.S.C. §§ 1391(b) and 1400(b). Defendant has
`
`committed acts of infringement and has a regular and established place of business in this District.
`
`Further, venue is proper because Defendant conducts substantial business in this forum, directly
`
`or through intermediaries, including: (i) at least a portion of the infringements alleged herein; and
`
`(ii) regularly doing or soliciting business, engaging in other persistent courses of conduct and/or
`
`deriving substantial revenue from goods and services provided to individuals in New York and
`
`this District.
`
`
`
`III.
`
`INFRINGEMENT
`
`A. Infringement of the ‘838 Patent
`
`6. On February 13, 2007, U.S. Patent No. 7,177,838 (“the ‘838 patent”, attached as Exhibit
`
`A) entitled “Method and Apparatus for Conducting Electronic Commerce Transactions Using
`
`Electronic Tokens” was duly and legally issued by the U.S. Patent and Trademark Office. AML
`
`IP, LLC owns the ‘838 patent by assignment.
`
`
`
`2
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 3 of 29
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`7. The ‘838 patent relates to a novel and improved methods and apparatuses for conducting
`
`electronic commerce.
`
`8. Tencent maintains, operates, and administers micropayment products and services that
`
`facilitate purchases from a vendor at micropayment levels, wherein prices for the products and
`
`services are listed in units of electronic tokens that infringes one or more claims of the ‘838 patent,
`
`including one or more of claims 1-28, literally or under the doctrine of equivalents. Defendant put
`
`the inventions claimed by the ‘838 Patent into service (i.e., used them); but for Defendant’s actions,
`
`the claimed-inventions embodiments involving Defendant’s products and services would never
`
`have been put into service. Defendant’s acts complained of herein caused those claimed-invention
`
`embodiments as a whole to perform, and Defendant’s procurement of monetary and commercial
`
`benefit from it.
`
`9. Support for the allegations of infringement may be found in the following preliminary
`
`table:
`
`
`
`
`
`
`
`Claim
`
`Analysis
`
`3
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 4 of 29
`
`[1.1] A method
`of conducting
`electronic
`commerce
`the
`over
`Internet using
`micropayment
`s, the method
`comprising:
`
`To the extent the preamble is limiting, Tencent America performs and induces
`others to perform a method of conducting electronic commerce over the
`Internet using micropayments.
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, Tencent provides Ring of Elysium, a free-to-play, multiplayer
`online battle royale game. The game supports microtransactions allowing
`the users to make in-game purchases for in-game currency, and/or other
`items such as avatars and weapons.
`
`
`
`
`
`
`
`Source: https://www.ringofelysiumonline.com/
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`4
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 5 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`Source:
`
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`5
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 6 of 29
`
`
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of opening a user
`account with a vendor for a user.
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`6
`
`[1.2] opening a
`user
`account
`with a vendor
`for a user;
`
`
`
`
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 7 of 29
`
`For example, Tencent (“vendor”) allows users to play the game, for
`example, by creating an account on Steam.
`
`
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`Source: https://store.steampowered.com/app/755790/Ring_of_Elysium/
`
`
`
`7
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 8 of 29
`
`Source: https://store.steampowered.com/app/755790/Ring_of_Elysium/
`
`
`
`
`
`Source: https://store.steampowered.com/join/
`
`
`
`8
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 9 of 29
`
`
`Source: https://support.steampowered.com/kb_article.php?ref=7826-IHXM-
`4853
`
`
`
`
`Source: https://support.steampowered.com/kb_article.php?ref=7141-OPGX-
`5121
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of issuing one or
`more electronic tokens from the vendor to the user account, wherein no
`
`9
`
`issuing
`[1.3]
`one or more
`electronic
`
`
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 10 of 29
`
`physical manifestation, other than a database entry, of the user account
`occurs, each electronic token having a value of at least a fraction of a dollar
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, Tencent allows users to purchase in-game currency or E-
`Points (“electronic token”) having a value of at least a fraction of a dollar.
`
`
`
`no
`
`from
`tokens
`the vendor to
`the
`user
`account,
`wherein
`physical
`manifestation,
`other
`than a
`database entry,
`of
`the user
`account
`occurs,
`electronic
`token having a
`value of
`at
`least a fraction
`of a dollar;
`
`each
`
`Source: https://www.ringofelysiumonline.com/
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`
`
`
`
`10
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 11 of 29
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`
`
`
`
`11
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 12 of 29
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of providing
`products and services that may be purchased from the vendor at
`micropayment levels, wherein prices for the products and services are listed
`in units of electronic tokens
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, the game contains in-game products and services (including
`but not limited to game pass, weapons, ammunition, and attire for player
`character) such that the products are listed in terms of in-game currency or
`E-Points (“electronic tokens”).
`
`[1.4] providing
`products and
`services
`that
`may
`be
`purchased
`the
`from
`at
`vendor
`micropayment
`levels, wherein
`prices for the
`products and
`services
`are
`listed in units
`of
`electronic
`tokens;
`
`
`
`
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`
`
`12
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 13 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`
`
`13
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 14 of 29
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37713/m21630/201910/832416.shtml
`
`
`
`14
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 15 of 29
`
`
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of permitting the
`user to select, at any participating vendor web site, a subset of the products
`and services for purchase from the vendor
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, the game’s online interface (“participating vendor web site”)
`allows the user to select and purchase products and services (including but not
`limited to game pass, weapons, ammunition, and attire for player character)
`through at least the servers provided by Tencent and publishers/developers.
`
`
`
`[1.5]
`permitting the
`user to select,
`at
`any
`participating
`vendor web
`site, a subset of
`the
`products
`and
`services
`for
`purchase
`from
`the
`vendor;
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`
`
`15
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 16 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`
`
`16
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 17 of 29
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37713/m21630/201910/832416.shtml
`
`
`
`17
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 18 of 29
`
`
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of computing at the
`participating vendor web site a total price for the selected subset of the
`products and services in units of electronic tokens
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, when the user wishes to purchase in-game products and services
`(including but not limited to game pass, weapons, ammunition, and attire for
`player character) a request is sent to the game servers owned at least by the
`game publishers/developers and Tencent. The servers compute the total price
`in terms of in-game currency or E-Points.
`
`
`
`[1.6]
`computing at
`the
`participating
`vendor web
`site
`a
`total
`price for
`the
`selected subset
`of the products
`and services in
`units
`of
`electronic
`tokens;
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`
`
`18
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 19 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`
`
`19
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 20 of 29
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`
`
`
`
`20
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 21 of 29
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37713/m21630/201910/832416.shtml
`
`
`
`Further, to the extent this element is performed at least in part by Defendant's
`software source code, Plaintiff shall supplement these contentions pursuant to
`production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of authorizing a
`purchase transaction at the participating vendor web site without requiring
`any third party authentication and a physical manifestation of the user account
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, the game servers authorize the purchase of the in-game
`products and services by using the account information of the user stored on
`the servers such that no third party authentication and a physical
`manifestation of the user account is required.
`
`[1.7]
`authorizing a
`purchase
`transaction at
`the
`participating
`vendor web
`site without
`requiring any
`third
`party
`authentication
`and a physical
`manifestation
`of
`the user
`account; and
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`
`
`21
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 22 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`
`
`22
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 23 of 29
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37713/m21630/201910/832416.shtml
`
`
`
`23
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 24 of 29
`
`
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`Tencent performs and induces others to perform the step of if the user account
`contains electronic tokens having a value equal to or greater than the total
`price, permitting the user to purchase the selected subset of the products and
`services without requiring the user to disclose personal information to the
`vendor, and subtracting the total price from the user account, wherein the
`purchase transaction is not subject to a minimum processing fee.
`
`
`
`This element is infringed literally, or in the alternative, under the doctrine of
`equivalents.
`
`
`
`For example, if the value of the order amounts to less than or equal to the E-
`Points present in the user account the purchase order is processed and the total
`value of E-Points are subtracted from the user account.
`
`
`
`Source: https://www.ringofelysiumonline.com/
`
`
`
`
`
`[1.8] if the user
`account
`contains
`electronic
`tokens having
`a value equal
`to or greater
`than the total
`price,
`permitting the
`user
`to
`purchase
`the
`selected subset
`of the products
`and
`services
`without
`requiring
`user
`disclose
`personal
`information to
`the
`vendor,
`and
`subtracting the
`total
`price
`from the user
`account,
`wherein
`purchase
`is
`transaction
`not subject to a
`minimum
`processing fee.
`
`the
`to
`
`the
`
`
`
`24
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 25 of 29
`
`
`Source: https://www.ringofelysiumonline.com/en-
`US/adventurerpass/index.html
`
`
`
`
`
`Source:
`https://store.steampowered.com/news/app/755790/view/2916604920698252
`047
`
`
`
`Source:
`https://www.ringofelysiumonline.com/webplat/info/news_version3/37706/3
`7707/37711/37712/m21630/201904/804916.shtml
`
`
`
`
`
`25
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 26 of 29
`
`
`
`Source: https://guides.gamepressure.com/ring-of-
`elysium/guide.asp?ID=47785
`
`
`
`Further, to the extent this element is performed at least in part by
`Defendant's software source code, Plaintiff shall supplement these
`contentions pursuant to production of such source code by the Defendant.
`
`
`
`
`
`These allegations of infringement are preliminary and are therefore subject to change.
`
`10. Tencent has and continues to induce infringement. Tencent has actively encouraged or
`
`instructed others (e.g., its customers and/or the customers of its related companies), and
`
`
`
`26
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 27 of 29
`
`continues to do so, on how to use its products and services (e.g., micropayment products
`
`and services that facilitate purchases from a vendor at micropayment levels, wherein prices
`
`for the products and services are listed in units of electronic tokens) such as to cause
`
`infringement of one or more of claims 1–28 of the ‘838 patent, literally or under the
`
`doctrine of equivalents. Moreover, Tencent has known of the ‘838 patent and the
`
`technology underlying it from at least the date of issuance of the patent.
`
`11. Tencent has and continues to contributorily infringe. Tencent has actively encouraged or
`
`instructed others (e.g., its customers and/or the customers of its related companies), and
`
`continues to do so, on how to use its products and services (e.g., micropayment products
`
`and services that facilitate purchases from a vendor at micropayment levels, wherein prices
`
`for the products and services are listed in units of electronic tokens) and related services
`
`such as to cause infringement of one or more of claims 1–28 of the ‘838 patent, literally or
`
`under the doctrine of equivalents. Moreover, Tencent has known of the ‘838 patent and
`
`the technology underlying it from at least the date of issuance of the patent.
`
`12. Tencent has caused and will continue to cause AML damage by direct and indirect
`
`infringement of (including inducing infringement of) the claims of the ‘838 patent.
`
`
`
`JURY DEMAND
`
`IV.
`
`AML hereby requests a trial by jury on issues so triable by right.
`
`V.
`
`PRAYER FOR RELIEF
`
`
`WHEREFORE, AML prays for relief as follows:
`
`a.
`
`enter judgment that Defendant has infringed the claims of the ‘838 patent;
`
`
`
`27
`
`

`

`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 28 of 29
`
`b.
`
`award AML damages in an amount sufficient to compensate it for Defendant’s
`
`infringement of the ‘838 patent in an amount no less than a reasonable royalty or lost
`
`profits, together with pre-judgment and post-judgment interest and costs under 35 U.S.C.
`
`§ 284;
`
`c.
`
`award AML an accounting for acts of infringement not presented at trial and an award by
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`the Court of additional damage for any such acts of infringement;
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`d.
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`declare this case to be “exceptional” under 35 U.S.C. § 285 and award AML its attorneys’
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`fees, expenses, and costs incurred in this action;
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`e.
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`declare Defendant’s infringement to be willful and treble the damages, including attorneys’
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`fees, expenses, and costs incurred in this action and an increase in the damage award
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`pursuant to 35 U.S.C. § 284;
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`f.
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`a decree addressing future infringement that either (i) awards a permanent injunction
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`enjoining Defendant and its agents, servants, employees, affiliates, divisions, and
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`subsidiaries, and those in association with Defendant from infringing the claims of the
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`Patents-in-Suit, or (ii) awards damages for future infringement in lieu of an injunction in
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`an amount consistent with the fact that for future infringement the Defendant will be an
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`adjudicated infringer of a valid patent, and trebles that amount in view of the fact that the
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`future infringement will be willful as a matter of law; and
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`g.
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`award AML such other and further relief as this Court deems just and proper.
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`Respectfully submitted,
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`Respectfully submitted,
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`/s/ David J. Hoffman
`David J. Hoffman
`254 W 15th St., Apt. 2C
`New York, New York 10011
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`28
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`Case 1:21-cv-04090-ALC Document 6 Filed 05/07/21 Page 29 of 29
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`(917) 701-3117 (telephone)
`djhoffman@djhoffmanlaw.com
`
`
`Ramey & Schwaller, LLP
`William P. Ramey, III (Pro Hac Vice anticipated)
`Texas State Bar No. 24027643
`Jeffrey Kubiak (Pro Hac Vice anticipated)
`Texas State Bar No. 24028470
`5020 Montrose Blvd., Suite 800
`Houston, Texas 77006
`(713) 426-3923 (telephone)
`(832) 900-4941 (fax)
`wramey@rameyfirm.com
`jkubiak@rameyfirm.com
`
`Attorneys for AML IP, LLC
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`29
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